State v. Davies
2017 Ohio 621
| Ohio Ct. App. | 2017Background
- On Jan. 29, 2011, Robert R. Davies was cited for OVI (first-degree misdemeanor) and two minor traffic offenses.
- On Apr. 4, 2011, Davies pled guilty to the OVI charge; other charges were dismissed; court imposed jail time (30 days, 30 suspended), license suspension, fines, DIP, and probation.
- On July 27, 2016, Davies moved to vacate the judgment and dismiss the complaint, relying on the U.S. Supreme Court’s decision in Birchfield v. North Dakota (June 23, 2016).
- The county court denied the motion, reasoning that new judicial rulings apply only to cases pending on the announcement date and Davies’s conviction was final.
- Davies appealed, arguing the trial court erred by denying his motion without a hearing and raising suppression/factual challenges to the traffic stop, evidence admissibility, and field sobriety testing.
- The appellate court affirmed, holding that collateral factual and suppression challenges are precluded after a guilty plea and that Birchfield did not provide a retroactive right that would invalidate Davies’s plea-based conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether post-conviction collateral attack may revisit suppression/factual issues after a guilty plea | The State: guilty plea removes factual-guilt issues; evidence admissibility is irrelevant to a valid plea | Davies: traffic stop lacked probable cause; evidence obtained in violation of 4th Amendment; field tests unreliable | Denied — guilty plea admits factual guilt and waives suppression/factual challenges |
| Whether Birchfield creates a retroactive right permitting vacatur of plea-based convictions | The State: new ruling not retroactive to final convictions; Birchfield doesn’t affect plea validity | Davies: Birchfield bars warrantless blood draws and precludes implied-consent penalties, so it should apply | Denied — Birchfield does not create a retroactive right that invalidates Davies’s plea; refusal consequences were administrative and plea-based conviction stands |
| Whether the trial court erred by denying motion without a hearing | The State: no hearing required because relief barred by plea and finality | Davies: entitled to a hearing on merits of motion | Denied — no duty to inquire into factual claims after valid guilty plea; court properly refused relief |
| Whether a claim based on a new U.S. Supreme Court decision can be raised outside postconviction time limits | The State: such claims may fit postconviction procedures only if a new right applies retroactively | Davies: invoked Birchfield as a new rule to bypass finality/time bars | Denied — Birchfield did not announce a retroactive right applicable to Davies’s situation |
Key Cases Cited
- Ali v. State, 819 N.E.2d 687 (Ohio 2004) (new judicial rulings generally apply only to cases pending on announcement date)
- Menna v. New York, 423 U.S. 61 (U.S. 1975) (a voluntary, intelligent guilty plea admits factual guilt and renders certain constitutional challenges irrelevant)
- Huber Heights v. Duty, 500 N.E.2d 339 (Ohio App. 1986) (guilty plea is an admission of guilt; factual guilt often suffices for conviction)
- State v. Gensert, 61 N.E.3d 636 (Ohio App. 2016) (no duty to investigate post-plea claims of innocence)
- State v. Elliott, 621 N.E.2d 1272 (Ohio App. 1993) (guilty plea waives suppression challenges)
- Birchfield v. North Dakota, 136 S.Ct. 2160 (U.S. 2016) (warrantless blood draws not permitted as search incident to arrest; distinctions between criminal penalties and administrative consequences for refusal)